New Comments on the IRS Voluntary Disclosure Program

- By : Parag Patel

…or start-up costs and costs of operation, maintenance, and purchase of services to provide information. Form 14457 relates to the Service’s Voluntary Disclosure Practice (“VDP”). The VDP is a longstanding…

The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers

- By : Parag Patel

…of cooperation. The VDP was announced via an IRS memorandum, not through the IRS website. The new VDP does not offer the finality and certainty that many noncompliant taxpayers wish…

IRS Updated Voluntary Disclosure Practice is a Game-Changer

- By : Parag Patel

Last week the IRS released a memorandum with new procedures for an “Updated Voluntary Disclosure Practice” impacting all voluntary disclosures. The new updated voluntary disclosure practice (VDP) is a game-changer…

All the Many FBAR Late Filing Procedures

- By : Parag Patel

…Taxpayers with undisclosed foreign income and assets. In 2018 the IRS closed this program and expanded the VDP Program. The new VDP Program is primarily for taxpayers who are considered…

How to Avoid Jail and Clean Up Tax Problems

- By : Parag Patel

…as the Voluntary Disclosure Practice (VDP). A taxpayer seeking to make a voluntary disclosure must do so by first requesting preclearance on Form 14457, Voluntary Disclosure Practice Preclearance Request and…

How to Avoid Criminal Prosecution Through Voluntary Disclosure

- By : Parag Patel

…not qualify for VDP. Another aspect of voluntary disclosure is that it must be timely as well. To be timely according to the IRS, they have to receive the disclosure…

The New IRS ERC Voluntary Disclosure Program

- By : Parag Patel

…potential civil litigation, penalties & interest. Under the ERC VDP, if the IRS paid interest on the employer’s ERC refund claim, the employer is not required to repay that interest….

IRS announces an update to its Voluntary Disclosure Practice Preclearance Request and Application

- By : Parag Patel

…need to disclose virtual currency transaction federal income tax consequences should avail themselves of this expanded opportunity to report their virtual currencies via the IRS CI VDP and avoid potential…

HSBC India Customer New Indictment Uncovers More HSBC Details

- By : Parag Patel

(VDP) program, which remains in effect after OVDI’s expiration, for protection against civil (and criminal) penalties. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax,…

Another Foreign Bank Charged by U.S. Department of Justice

- By : Parag Patel

…involved with the foreign banks in OVDI and VDP disclosures to avoid future possible complications and prosecution. The new indictment cites 15 clients, without identifying them, who allegedly used Casadei…

Fifth HSBC India Customer indicted for tax evasion this year

- By : Parag Patel

…persuade offshore accountholders who cannot decide whether to disclose past foreign account noncompliance to the IRS via the IRS Voluntary Disclosure Practice (VDP) program, which remains in effect after OVDI’s…

Another Bank Discloses Accountholders: Credit Suisse to Turn Over U.S. Account Data

- By : Parag Patel

…to file a traditional voluntary disclosure via the IRS VDP program that would allow them to avoid potential criminal prosecution. In February 2009, UBS AG, the biggest Swiss bank, avoided…